A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license — even if the state’s money transmission law does not expressly address the regulation of virtual currency. This interpretation has the potential to significantly disrupt current compliance approaches taken by some organizations engaging in virtual currency activity, and could make a challenging regulatory landscape even tougher to navigate.
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At the Intersection of Technology, Law, and Business